Tax Controversy

Taxpayers are increasingly finding themselves embroiled in contentious tax issues. These issues are complex, costly, and time-consuming to resolve as a result of enhanced reporting requirements and enforcement efforts by taxing authorities, demand for tax revenues, worldwide focus on minimization of tax base erosion and profit shifting, increasingly complex tax laws, sharing and exchange of information, and increasing globalization and complexity of business operations.

Foley’s tax controversy practice is comprised of seasoned practitioners, including former tax enforcement and other government officials, who use their expertise and insight to craft efficient and innovative strategies to obtain favorable results for their clients. Our tax controversy attorneys have represented clients in all phases of tax disputes and have collectively handled thousands of cases, administrative proceedings, and alternative dispute resolution proceedings involving state, federal, and international tax issues and disputes, both civil and criminal, including:

• Civil and criminal tax litigation before state and federal trial and appellate courts and administrative bodies, including the U.S. Tax Court, U.S. District Courts, and U.S. Court of Federal Claims
• IRS audits, protests, and appeals
• Alternative dispute resolution, including fast track settlement, post appeals mediation, and the rapid appeals process
• Transfer pricing
• Requests for competent authority assistance, unilateral, bilateral, and multi-lateral advance pricing agreements and private letter rulings
• Tax shelter cases, including injunction and penalty cases
• International and offshore tax compliance and reporting, including international information returns and Report of Foreign Bank and Financial Accounts filing requirements and penalties
• Collection proceedings
• State and local taxes
• Excise and employment taxes
• Estate and gift taxes
• Tax return preparer regulations and penalties
• White-collar crime and government investigations

Clients are best served when disputes and litigation are avoided in the first place. Our attorneys use their deep, across-the-board understanding of complicated tax procedures and substantive issues to counsel clients on their business operations and structures and assist clients with planning matters and formulation of creative, business-oriented strategies geared toward dispute avoidance.